Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Luxembourg in International Tax written by Marc Schmitz and published by . This book was released on 2015 with total page 610 pages. Available in PDF, EPUB and Kindle. Book excerpt: Luxembourg in International Tax' takes an in-depth look at corporate taxation in Luxembourg and the tax issues that may be of interest in an international environment. Although it principally focuses on those areas of interest to international investors and tax experts requiring a clear explanation of corporate tax in Luxembourg, it is also of interest to locally based practitioners. The first edition rapidly became a standard reference work in Luxembourg tax literature, and its reputation was maintained through the second edition, which continued being referred to and selling long after the date of issue. 0This new edition of the book is updated to incorporate tax developments on the national level up to January 2015, including the latest changes on the exchange of information, advance tax clearances and the codification of the arm’s length standard. It also covers Luxembourg’s intellectual property box regime, private wealth management companies and other investment entities, and the taxation of financing activities in Luxembourg. Furthermore, it contains a new chapter on tax treaties, which provides insight into the particularities of Luxembourg’s treaty network and its interaction with domestic law. 0The book provides a vast amount of up-to-date information combined with an in-depth analysis of business taxation in Luxembourg. It is a valuable guide for international tax experts wishing to gain a better understanding of corporate tax in Luxembourg as well as for locally based practitioners. With numerous examples given in each chapter, it will also be of interest to students.
Download or read book Employment Law Review written by Erika C Collins and published by Law Business Research Ltd.. This book was released on 2017-04-07 with total page 1263 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Employment Law Review, edited by Erika C Collins of Proskauer Rose LLP, serves as a tool to help legal practitioners and human resources professionals identify issues that present challenges to their clients and companies. As well as in-depth examinations of employment law in 48 jurisdictions, the book provides further general interest chapters covering the variety of employment-related issues that arise during cross-border merger and acquisition transactions, aiding practitioners and human resources professionals who conduct due diligence and provide other employment-related support in connection with cross-border corporate M&A deals. Other chapters deal with global diversity and inclusion initiatives across the globe, social media and mobile device management policies, and the interplay between religion and employment law. Contributors include: Els de Wind, Van Doorne; Annie Elfassi, Loyens Loeff. "e;Excellent publication, very helpful in my day to day work."e; - Mr Frederic Thoral, Head of HR, BNP Paribas"e;Excellent coverage and detail on each country is brilliant."e; - Mr Raani Costelloe, General manager of Legal and Business Affairs, Sony music Entertainment, Australia"e;An excellent resource for in-house counsel for a company with an international footprint."e; - Mr John R Pendergast, Senior Counsel, BASF Corporation, USA"e;It's invaluable to any lawyer dealing with cross-border and privacy-related employment issues and is a cornerstone to my own legal research"e; - Oran Kiazim, Vice President, Global Privacy, SterlingBackcheck, UK
Download or read book Luxembourg in International Tax Planning written by Philip J. Warner and published by IBFD. This book was released on 2004 with total page 588 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study, divided into five parts: a short introduction to Luxembourg as a country and financial centre; calculation of profits taxes and other taxes to which a fully-taxable resident business is subject; the fully-taxable "special purposes vehicles" available in Luxembourg including banking and reinsurance; tax exempt vehicles, the 1929 holding company and investment funds; and corporate reorganizations and examples of how Luxembourg could be used in international tax planning
Download or read book Withholding of Tax on Nonresident Aliens and Foreign Corporations written by and published by . This book was released on 2000 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Preventing the Artificial Avoidance of Permanent Establishment Status written by OCDE, and published by OCDE. This book was released on 2015-10-22 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.
Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Download or read book U S Income Taxation of Foreign Corporations and Non resident Aliens written by Sidney I. Roberts and published by . This book was released on 1966 with total page 1132 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of Foreign Business Income Within the European Internal Market written by Jérôme Monsenego and published by IBFD. This book was released on 2012 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriality or on the principle of worldwide taxation, are in conflict with the objective of achievement of the internal market. This objective is indeed difficult to reach when it comes to the taxation of foreign income, given that the Member States are far from taxing companies doing business cross-border as if their operations were purely domestic. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation and the attribution of profits to permanent establishments. This dissertation analyses this conflict on the basis of a study of the case law of the European Court of Justice as well as some of the key provisions of the European treaties. It appears that both the fiscal principle of territoriality and the principle of worldwide taxation give rise to complex issues of compatibility with the law of the European Union. Although the analysis conducted throughout the dissertation provides some guidance for the taxation of the foreign business income of companies, it is concluded that the Court cannot, by itself, efficiently resolve the conflict between such taxation and the objective of achievement of the internal market.
Download or read book Building Tax Culture Compliance and Citizenship A Global Source Book on Taxpayer Education Second Edition written by OECD and published by OECD Publishing. This book was released on 2021-11-24 with total page 150 pages. Available in PDF, EPUB and Kindle. Book excerpt: Widespread voluntary tax compliance plays a significant role in countries’ efforts to raise the revenues necessary to achieve Sustainable Development Goals. As part of this process, governments are increasingly reaching out to taxpayers – current and future – to teach, communicate and assist them in order to foster a “culture of compliance” based on rights and responsibilities, in which citizens see paying taxes as an integral aspect of their relationship with their government.
Download or read book EU Freedoms Non EU Countries and Company Taxation written by D.S. Smit and published by Kluwer Law International B.V.. This book was released on 2012-06-01 with total page 864 pages. Available in PDF, EPUB and Kindle. Book excerpt: In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
Download or read book Taxing Wages 2021 written by OECD and published by OECD Publishing. This book was released on 2021-04-29 with total page 651 pages. Available in PDF, EPUB and Kindle. Book excerpt: This annual publication provides details of taxes paid on wages in OECD countries. It covers personal income taxes and social security contributions paid by employees, social security contributions and payroll taxes paid by employers, and cash benefits received by workers. Taxing Wages 2021 includes a special feature entitled: “Impact of COVID-19 on the Tax Wedge in OECD Countries”.
Download or read book Taxation of Foreign Investment in the United States written by United States. Congress. Senate. Committee on Finance. Subcommittee on Taxation and Debt Management Generally and published by . This book was released on 1979 with total page 264 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Treaty Interpretation written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2001-12-19 with total page 402 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.
Download or read book The principle of non discrimination in international and European tax law written by Niels Bammens and published by IBFD. This book was released on 2012 with total page 1151 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.
Download or read book EU Citizenship and Direct Taxation written by Erik Ros and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 323 pages. Available in PDF, EPUB and Kindle. Book excerpt: Freedom of movement is a key principle of the European Union (EU) resulting in the right of every EU citizen to move and reside freely within the EU. Many EU citizens work in other Member States than their Member State of origin. Direct taxes are not as such covered in the treaties and therefore have much smaller bases for harmonization at EU level than indirect taxes. As a result, decisions of European Court of Justice (ECJ) on the clash between the EU principle of free movement and Member States’ direct tax rules have a significant effect on national direct tax systems. This book focuses on the relation between free movement rights of EU citizens and the legal autonomy of Member States in the area of direct taxation and will immediately engage tax practitioners and scholars. The author asks (and answers) the question: Has the willingness at EU level to make EU citizenship a key driver behind the integration process come at the expense of national direct tax autonomy? The book’s incomparably thorough analysis of the distinctive evolution, mainly via ECJ case law, of the relation between the EU principle of free movement of persons and Member States’ direct tax rules includes in-depth discussion of the following elements and more: – the concept of EU citizenship in the EU’s constitutional and institutional development; – how the ECJ has interpreted the concept of free movement with regard to economically inactive persons; – how the notion of EU citizenship has widened the ECJ’s view on treaty access; – how the ECJ has addressed the clash between free movement of persons and direct taxation in the EU’s constitutional context; and – numerous tax policy initiatives with regard to EU citizens before and after the Treaty of Lisbon This is the first book to investigate in such detail how the ECJ has tried to reconcile specific national direct tax rules with the general EU principle of free movement of persons from the perspective of EU citizenship. This book explains that the ECJ is in the process of reconceptualizing the market freedoms relating to the free movement of persons, also in the area of direct taxation, as part of a broader EU citizenship right for all economically active EU citizens to pursue an economic activity in a cross-border context; a right beyond the aim of realization of the internal market. As an extremely important analysis of the influence of EU law on the direct tax autonomy of Member States, this book is sure to be itself of great influence in the practice and study of taxation in the EU.
